COLJI-Crim. 13:28

The elements of the crime of failure to make proof of ownership

available are:

1. That the defendant,

2. in the State of Colorado, at or about the date and place charged,

3. was a secondhand dealer or a dealer and retailer of new goods

who sold goods at a flea market or similar facility, and

4. sold or offered for sale,

5. [baby food of a type usually consumed by children under three

years of age] [cosmetics] [devices] [drugs] [infant formula]

[batteries] [razor blades], and

6. failed to make proof of ownership available to any peace officer

for inspection at any reasonable time.

[7. and that the defendant’s conduct was not legally authorized by

the affirmative defense[s] in Instruction[s] ___.]

After considering all the evidence, if you decide the prosecution has

proven each of the elements beyond a reasonable doubt, you should find

the defendant guilty of failure to make proof of ownership available.

After considering all the evidence, if you decide the prosecution has

failed to prove any one or more of the elements beyond a reasonable doubt,

you should find the defendant not guilty of failure to make proof of

ownership available.